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The 2030 energy efficiency (EE) objective was set at 32.5% based on a GHG emissions reduction target of 80-95% by 2050. Consequently, in order to reach carbon neutrality by 2050, the 2030 EE objective should be increased accordingly. Iberdrola strongly supports the proposal to increase this value to 36%.

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.

Synergrid is the Belgian association representing all Belgian TSOs and DSOs (electricity and gas). In our response we are focussing mainly on article 25 about energy transformation, transmission and distribution in the recast EED. Synergrid can comfortably state that energy efficiency runs already for many years through the ‘veins’ of its member companies.

• This package should be framed within the 2030 and 2050 goals. Hence, it must: o be consistent with the goals and principles of the Green Deal; o respect the basic principles of liberalisation; o be aligned with the decarbonisation-enabling initiatives of the CEP; o be realistic regarding the contribution of hydrogen and gas to carbon neutrality (i.e.

• This package should be framed within the 2030 and 2050 goals. Hence, it must: o be consistent with the goals and principles of the Green Deal; o respect the basic principles of liberalisation; o be aligned with the decarbonisation-enabling initiatives of the CEP; o be realistic regarding the contribution of hydrogen and gas to carbon neutrality (i.e.

Synergrid is focusing in its response mainly on the: • Directive on common rules for the internal markets in renewable and natural gases and in hydrogen. • Regulation on the internal markets for renewable and natural gases and for hydrogen. Our paper and response starts with a general position on the proposed EU legislation, followed by the main attention points in the new proposed legislation.

• CROSS-SUBSIDIES BETWEEN DIFFERENT ENERGY CARRIERS. Cross-subsidies means deviating from the cost-reflective tariffs principle, thus distorting competition between different energy vectors, which is the essence of an efficient energy system integration according to Commission's Strategy itself.

Synergrid, Association representing the Belgian gas TSO Fluxys and DSO’s Fluvius, Ores, Resa and Sibelga welcomes the possibility to provide feedback to this public consultation and acknowledge the efforts of the EC to accelerate methane emissions reduction to support the EU’s climate ambition for 2030 and its 2050 climate neutrality objective.

Synergrid is focusing in its response on the: • Regulation on methane emissions reduction in the energy sector. Our paper and response starts with a general position on the proposed EU legislation, followed by the main attention points in the new proposed legislation. Amended text proposals can be found in the Annex I (still in elaboration). Paper in attachment.

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal through the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.

Synergrid is focusing in its response mainly on the: • Directive on common rules for the internal markets in renewable and natural gases and in hydrogen. • Regulation on the internal markets for renewable and natural gases and for hydrogen. Our paper and response starts with a general position on the proposed EU legislation, followed by the main attention points in the new proposed legislation.

• DEPENDENCY ON FOSSIL GAS. To reduce this dependency, fossil gas-based H2 should be excluded from the definition of low-carbon H2 (even when fitted with CCS/CCU). This is especially relevant as this Directive includes measures to promote low-carbon gases, thus risking increasing such dependency. • FOSSIL FUEL COMPARATOR. The renewable and low-carbon gases injected are intended to substitute fossil gas.